UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

MasterMine Software, Inc., Plaintiff, v. Microsoft Corporation, Defendant.

Court File No. ____________

COMPLAINT AND JURY DEMAND

MasterMine Software, Inc. (MasterMine), by and through its undersigned counsel, for its Complaint against Microsoft Corporation (Microsoft), states the following. THE PARTIES 1. MasterMine is a corporation organized under the laws of the State of

Minnesota and has its principal place of business at 4200 Toledo Avenue South, Minneapolis, Minnesota 55416. 2. On information and belief, Microsoft is a corporation organized under the

laws of the State of Washington, with its principal place of business located at One Microsoft Way, Redmond, Washington 98052, and is doing business in this judicial district and elsewhere. On information and belief, Microsoft also has places of business located at 3601 West 76 Street, Minneapolis, Minnesota 55435; 8300 Norman Center Drive, Bloomington, Minnesota 55437; and in the Mall of America, 162 South Avenue, Bloomington, Minnesota 55425.

JURISDICTION AND VENUE 3. This is an action for patent infringement, arising under the patent laws of

the United States, 35 U.S.C. 1 et. seq., including without limitation 35 U.S.C. 271 and 281. This Court has exclusive jurisdiction over such actions under 28 U.S.C. 1331 and 1338(a). 4. This Court has general and specific personal jurisdiction over Microsoft at

least because Microsoft has places of business in Minnesota. This Court further has jurisdiction over Microsoft at least because it systematically and continuously transacts business in Minnesota, including the sale of infringing products. 5. Venue is proper in this judicial district pursuant to 28 U.S.C. 1400(b)

because infringement by Microsoft has occurred in this district. Venue is also proper pursuant to 28 U.S.C. 1391(b) and 1391(c) since a substantial part of the events giving rise to the claims occurred in this district, and Microsoft does business in this district and is subject to personal jurisdiction in this district. PATENT INFRINGEMENT 6. MasterMine is the owner of United States Patent Nos. 7,945,850 (the 850

patent) and 8,429,518 (the 518 patent), both of which are titled Data Mining and Reporting. The 850 patent issued on May 17, 2011. A true and correct copy of the 850 patent is attached hereto as Exhibit A.1 The 518 patent issued on April 23, 2013.

On April 17, 2013, MasterMine filed a request with the Patent Office for a certificate of correction addressing a typographical error in the 850 patent. A true and correct copy of that request is attached hereto as Exhibit B.

A true and correct copy of the 518 patent is attached hereto as Exhibit C. The 850 and 518 patents are hereinafter collectively referred to as the patents-in-suit. 7. The patents-in-suit relate generally to the interface between customer

relationship management (CRM) and spreadsheet software applications. The patents disclose and claim novel methods and systems that mine data from CRM databases and automatically generate spreadsheet pivot tables presenting the potentially voluminous CRM data in useful summary reports. 8. On information and belief, Microsoft has made, used, sold, and offered for

sale computer software that directly infringes, either literally or under the doctrine of equivalents, one or more claims of the patents-in-suit, including its Microsoft Dynamics CRM, Microsoft Excel, and Microsoft Office products. 9. On information and belief, Microsoft has further induced or contributed to

the infringement of one or more claims of the patents-in-suit by others, including by the use of the Export to Excel feature of Microsoft Dynamics CRM. On information and belief, the Export to Excel feature includes options for creating a Dynamic PivotTable in a Microsoft Excel worksheet, using MasterMines patented methods and systems. On information and belief, the Dynamic PivotTable feature in Microsoft Dynamics CRM is specifically designed to perform the methods claimed in the patentsin-suit, and is not a staple article of commerce suitable for substantial non-infringing uses. Further, on information and belief, Microsoft provides detailed instructions directing users to operate the Export to Excel feature of Microsoft Dynamics CRM to

create pivot tables within Excel worksheets in the manner disclosed and claimed by the patents-in-suit. 10. MasterMine has been and continues to be irreparably harmed, and has

suffered and continues to suffer damages as a result of Microsofts infringement of the patents-in-suit. MasterMine is entitled to recover damages that adequately compensate it for the infringement in an amount to be determined at trial, which cannot by law be less than a reasonable royalty. 11. On information and belief, Microsofts infringing conduct will continue to

harm MasterMines business unless and until such conduct is enjoined by the Court. JURY DEMAND 12. MasterMine requests a trial by jury. PRAYER FOR RELIEF 13. MasterMine respectfully requests that the Court enter judgment in its favor

and against Microsoft as follows: A. An entry of judgment that Microsoft has directly and indirectly infringed the 850 and 518 patents, either literally or under the doctrine of equivalents; B. A permanent injunction against Microsofts further infringement of the patents-in-suit; C. An award of damages adequate to compensate MasterMine for Microsofts infringement, together with prejudgment interest from the date the infringement began; 4

D.

An award of any other damages permitted under 35 U.S.C. 284 and 285; and

E.

Such other and further relief that this Court or a jury may deem just and proper.

Dated: April 25, 2013

/s/ Lora M. Friedemann Lora M. Friedemann (#0259615) lfriedemann@fredlaw.com Kurt J. Niederluecke (#0271597) kniederluecke@fredlaw.com Grant D. Fairbairn (#0327785) gfairbairn@fredlaw.com Adam R. Steinert (#0389648) asteinert@fredlaw.com Ted C. Koshiol (#0390542) tkoshiol@fredlaw.com FREDRIKSON & BYRON, P.A. 200 South Sixth Street, Suite 4000 Minneapolis, MN 55402-1425 Telephone: 612.492.7000 Facsimile: 612.492.7077

Attorneys for Plaintiff

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